REPORT 


T  R  ANSPOR  T  AT  ION  COM  M  ITT  EE 


OF  THE 


ON 


"  REFORMS  IN  RAILROAD  BILLS  OF  LADING  AND  IN 
CLASSIFICATION  OF  FREIGHT." 


Head  before  the  Association  and  Representatives  of  Railroads  terminating 
in  Boston,  at  a  Regular  Meeting  of  the  Association,  held  in 
Boston,  on  the  17th  of  December,  1888. 


PRINTED  BY  SPECIAL  REQUEST. 


B  0  S  T  0  N  : 
ALFRED  MUDGE  &  SON,  PRINTERS, 
No.  24  Franklin  Street. 
1889  . 


BOSTON  EXECUTIVE  BUSINESS  ASSOCIATION. 
OFFICERS,  1888-89. 


HERSEY  B.  GOODWIN, 

15  India  Street,  Boston, 

Representing  Chamber  of  Commerce. 

LAMONT  G.  BTJRNHAM, 

75  State  Street,  Boston, 

Representing  Coal  Trade  Association 

W.  ROWLAND  NOROROSS, 

14  Merchants  Row,  Boston^ 

Representing  Earthen-ware  and  Glass  Trade  Ass'n. 

GEORGE  H.  LEONARD, 

207  Purchase  Street,  Boston, 

Representing  Oil  Trade  Association. 

pt  vectors. 

JONATHAN  A.  LANE, 

22(>  Devonshire  Street,  Boston, 

Representing  Merchants  Association. 

THOMAS  L.  JENKS, 

57  Court  Street,  Boston, 

Representing  Druggists  Association. 

WILLIAM  IT.  SAY  WARD, 

164  Devonshire  Street,  Boston, 

Representing  the  Master-Builders  Association. 


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REPORT 


Mr.  President,  and  Gentlemen  of  the  Boston  Executive  Business 
Association  : 

Your  committee  take  up  the  matters  referred  to  them  with  extreme 
diffidence,  as  the)7  touch  not  only  the  interest  of  every  person  in  the 
United  States  who  ships  or  receives  a  pound  of  merchandise,  trans- 
ported by  what  are  termed  the  "  common  carriers."  but  also  the  rela- 
tion of  the  common  carriers  and  what  responsibility  they  should  bear, 
and  that  without  putting  the  shipper  or  receiver  to  unnecessary  and 
illegitimate  trouble  or  expense. 

We  state  the  following  postulates  :  — 

First.  All  common  carriers  should  be  responsible  for  goods  re- 
ceipted for  by  them  in  the  bill  of  lading. 

Second.  They  should  be  responsible  for  the  quantity  expressed  in 
the  bill  of  lading. 

Third.  Freight  should  be  settled  for  where  the  goods  are  received, 
as  per  the  terms  of  the  bill  of  lading,  whether  the}7  may  be  over- 
charged or  not,  by  the  lines  over  which  the  goods  have  been  trans- 
ported, and  which  have  been  paid  by  the  last  company  receiving  and 
delivering  the  merchandise  to  the  receiver. 

Fourth.  The  putting  of  "O.  R."  and  "released"  in  railwa}7 
receipts  and  bills  of  lading  is  unwarranted  by  the  law  that  governs 
O  common  carriers,  and  should  be  abandoned  not  only  because  it  is 

illegal,  but  also  a  great  annoyance  to  the  public,  and,  we  firmly 
believe,  of  doubtful  utility  to  the  "common  carriers." 

As  the  matters  which  we  propose  to  consider^at  this  time  relate 
H  entirely  to  "  common  carriers,"  of  private  carriers  we  will  only  say 

in  general  terms  that  "  the  general  rules  which  regulate  contracts  and 
£  mutual  obligations  apply  to  the  duties  and  rights  of  private  carriers, 

with  little  or  no  qualification  "  ;  but  the  common  carrier  has  rights  and 
assumes  responsibilities  not  common  to  the  private  carrier.  The 
rights  and  responsibilities  of  the  common  carrier  may  be  briefly  stated 
thus  :  He  is  bound  to  take  the  goods  that  are  proper  to  be  transported 
and  in  proper  condition  for  transportation  of  all  who  offer,  and  take 


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due  care  and  make  due  transport  and  delivery  of  them.  "  He  has  a 
lien  on  the  goods  which  he  carries "  (which  the  private  carrier  has 
not)  ;  "  he  is  liable  for  all  loss  or  injury  to  the  goods  under  his 
charge,  although  wholly  free  from  negligence,  unless  the  loss  happens 
from  the  act  of  God  or  from  the  public  enemy." 

The  added  responsibility  probably  arises  from  several  causes  :  first, 
in  the  case  of  railroad  corporations,  they  have  received  a  charter  from 
the  States  to  enable  them  to  do  this  business,  and  are  given  valuable 
rights  and  privileges,  such  as  the  right  to  demand  prepayment  of 
freight ;  and  second,  a  lien  on  the  goods  transported  till  paid  for  such 
transportation.  "  The  common  carrier  is  to  a  certain  extent  a  public 
officer,  and  the  recognized  confidence  that  is  reposed  in  them,  the 
power  they  have  over  the  goods  intrusted  to  them,  and  the  opportu- 
nity to  defraud  the  owner  of  them,  and  }^et  make  it  appear  that  he 
was  not  in  fault,  which  fault  might  be  difficult  of  proof  by  the  owner 
of  the  goods,  and  the  rule  is  intended  to  hold  common  carriers 
responsible  wherever  it  was  possible  that  they  caused  the  loss  either  by 
negligence  or  design." 

"The  general  principles  of  agency  extend  to  'common  carriers' 
and  make  them  liable  for  the  acts  of  their  agents  done  while  in  the 
discharge  of  their  agency  or  employment ;  so  the  knowledge  of  their 
agents  is  the  knowledge  of  the  carriers,  if  the  agent  be  authorized 
expressly,  or  by  the  nature  of  this  employment,  to  receive  this  notice 
or  knowledge." 

The  carriers  are  not  only  liable  on  their  own  lines,  but  where  they 
unite  to  form  a  long  line,  extending  over  different  lines  and  States  on 
through  rates,  which  are  to  be  divided  as  may  have  been  agreed, 
"they  are  all  liable  for  a  loss  on  any  part  of  the  lines." 

Again,  "  if  they  are  not  so  united,  but  say  they  are  so  or  say  what 
indicates  they  are  so  "  (as  by  giving  or  recognizing  through  bills  of 
lading  over  such  road),  "  they  justify  the  shipper  and  receiver  in  sup- 
posing they  are  united,  and  thus  they  are  equally  liable." 

If  the  foregoing  propositions,  as  to  the  acknowledged  and  proper  lia- 
bility of  the  common  carriers  are  correct,  the  next  question  arises, 
How  far  this  liability  can  be,  and  how  far  it  should  be,  limited. 

Our  first  proposition  was,  that  common  carriers  should  be  liable 
for  the  goods  receipted  for  and  stated  in  the  bill  of  lading. 

Of  course  the  bill  of  lading  must  be  signed  by  an  authorized  agent 
or  it  is  not  a  bill  of  lading  but  a  forgery,  and  of  no  binding  force  on 
any  one  or  party  but  the  forger.    But  it  has  occurred  in  the  past  that 


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a  genuine  bill  of  lading  has  come  forward  accompanied  with  drafts  for 
the  value  of  the  goods,  and  the  drafts  have  been  paid,  when  in  the 
end  it  has  been  found  that  the  goods  had  never  been  shipped. 

We  are  aware  that  the  courts  in  England  have  decided  that  ves- 
sels are  liable  only  for  the  goods  actually  received,  even  though 
the  bill  of  lading  be  signed  by  the  captain,  who  only  is  authorized  to 
sign  such  bill  of  lading;  the  justice  stating  the  following:  "  We 
think  that  when  a  captain  has  signed  bills  of  lading  for  a  cargo  that  it 
is  actually  on  board  his  vessel,  his  power  is  exhausted  ;  he  has  no  right 
or  power  by  signing  other  bills  of  lading  for  goods  that  are  not  on 
board  to  charge  his  owners." 

But  later,  in  1868,  an  English  court,  the  judges  all  concurring,  de- 
cided "  that  delivery  to  the  agent  of  the  ship  for  the  purpose  of  loading 
is  sufficient  to  create  liability  on  the  owners'  part,"  and  the  final  settle- 
ment of  the  celebrated  Green  &  Co.  cotton  case  in  this  country  seems 
to  have  settled  the  principle  that  a  genuine  bill  of  lading  is  good  for 
the  merchandise  or  its  value. 

It  seems  to  us  the  foregoing  acknowledged  principles  of  law,  that 
the  common  carriers  are  responsible  for  the  acts  of  their  agents, 
should  be  strictly  enforced,  else  it  is  quite  possible,  we  may  say  prob- 
able, that  a  captain  or  agent  who  would  be  guilty  of  the  issuing  of  a 
bill  of  lading  for  goods  not  received  would  be  much  more  likely  to 
make  other  disposition  of  a  part  of  the  goods  for  his  own  personal 
benefit.  The  common  carriers  should  have  honest  agents  ;  if  not, 
they  and  not  the  holder  of  the  bill  of  lading  should  be  the  sufferer. 

As  to  the  quantity  shipped,  common  carriers  attempt  to  transfer 
a  part  of  the  risk  upon  the  shipper  or  receiver,  as  the  ownership  may 
rest,  by  various  insertions  in  the  bill  of  lading,  thereby  limiting  as  far 
as  possible  all  responsibility  beyond  that  of  the  private  carrier,  beyond 
which  they  well  know  they  cannot  go.  The  common  carrier  occupies 
a  position  of  trust  for  the  shipper  of  the  goods  and  the  receiver.  We 
think  they  are  bound  to  know  the  quantity  of  the  article  received,  and 
not  to  issue  a  bill  of  lading  till  they  have  such  knowledge,  and  when 
the  bill  of  lading  has  been  signed  they  are  equitably  bound  to  deliver 
all  they  received  to  transport.  It  may  be  here  said  that  for  the  con  • 
venience  of  shippers  cars  are  sent  to  elevators  and  warehouses  where 
they  have  not  agents  or  scales,  and  in  such  cases  some  such  words  as 
"shipper's  count"  or  "  shipper's  weight"  are  inserted  in  the  bill  of 
lading ;  but  we  claim  that  no  bill  of  lading  should  be  issued  till  the 
common  carriers  have  satisfied  themselves  as  to  what  the  bill  of  lad- 


4 


ing  should  cover,  then  the}'  can  sign  a  bill  of  lading  that  shall  insure 
the  delivery  of  the  goods  or  pay  for  them. 

As  to  settlement  at  point  of  delivery,  we,  as  merchants,  can  see  no 
legitimate  reason  why  we  should  pay  anything  beyond  that  demanded 
by  the  bill  of  lading,  as  the  delivering  company  can,  if  it  shall  so 
determine,  retain  in  its  hands  all  the  freight  specified  in  the  bill  of 
lading  till  any  irregularity  in  previous  billing  is  adjusted.  It  prob- 
ably will  be  replied  that  such  is  not  the  custom  of  connecting  railroad 
companies,  but  the  usual  course  is  for  each  to  pay  the  connecting  road 
all  back  charges,  and  they  are  left  to  collect  the  amount  paid  by 
them,  with  their  charge  for  the  distance  carried  by  them.  In  reply 
we  say,  do  not  pay  more  than  should  be  the  aggregate  proportion  of 
the  preceding  companies  ;  but  if  you  have  or  shall  do  so,  as  a  part  of 
the  line,  it  is  your  duty  to  adjust  the  matter  between  your  different 
parties  in  the  transaction. 

It  may  be  also  added  by  the  common  earner,  that  they  receive 
merchandise  from  roads  with  which  they  have  no  agreed  rates,  and 
that  legitimately  they  have  no  right  to  issue  a  through  bill  of  lading 
that  should  bind  the  line,  or  any  road  in  the  line,  and  the  delivery 
road  should  not  be  bound  to  adjust  any  over-charges  back  of  the  line 
of  which  they  are  an  acknowledged  part.  To  this  we  reply,  the  first 
link  in  the  connecting  line  should  require,  in  the  manifest  that  accom- 
panies the  shipment,  a  statement  of  the  through  rate  at  which  the 
merchandise  has  been  billed  through,  and  this  first  road  of  the  regu- 
lar line  should  see  that  the  amount  asked  of  them  by  the  road  deliv- 
ering to  them  is  only  such  part  of  the  rate  expressed  in  the  bill  of 
lading  as  shall  leave  the  line  their  agreed  rates  to  carry  the  merchan- 
dise to  the  consignee  at  the  point  designated  in  the  bill  of  lading. 
This  course  being  adopted,  there  is  no  chance  or  place  for  over, 
charges,  except  by  clerical  errors,  which  should,  and  doubtlesss 
would,  always  be  promptly  corrected  by  the  road  making  the  final 
delivery. 

The  official  classification  issued  by  the  joint  committee  of  the  rail- 
way companies  to  the  Interstate  Commissioners,  and  adopted  largely 
by  the  railway  companies  east  of  the  Mississippi  River,  assumes,  ami 
tries  to  put  in  force,  a  practice  which  we  deem  unfair  to  the  public, 
in  that  it  attempts  to  absolve  the  railway  companies  from  responsi- 
bilities in  case  the  property  is  injured  in  transit,  which  responsibility 
manifestly  and  legitimately  belongs  to  them  as  common  carriers. 

It  will  be  found  in  this  joint  classification  that  almost  all  freight 


5 


which  is  liable  to  injury  by  the  usual  causes  of  rough  handling, 
derailment,  collision,  and  violent  stopping,  starting,  or  switching,  are 
forced  into  the  "  O.  R  "  (owners'  risk)  class,  which  is  written  upon 
the  railroad  receipt  or  bill  of  lading,  leaving  the  owner  of  the  injured 
goods  the  remedy  of  a  suit  at  law  ;  and  while  the  liability  of  the  com- 
mon carrier,  as  before  stated,  is  that  they  shall  deliver  the  property 
in  like  good  condition,  acts  of  God  and  the  nation's  enemies  only 
excepted,  yet  having  accepted  such  a  receipt  or  bill  of  lading  (in 
many  cases  not  aware  of  its  purport  and  intended  force) ,  with  owners' 
risk  of  leakage,  breakage,  chafing,  or  use  of  hooks,  the  owners  are  at 
great  disadvantage  to  secure  their  rights. 

The  right,  yea  more,  the  duty  of  the  officers  of  the  railway  com- 
pany to  protect  itself,  as  to  extra-hazardous  freight  and  rascalit}^  of 
either  shipper  or  receiver,  is  not  questioned  ;  but  if  the  business  com- 
munity shall  acquiesce  in  the  present  classifications,  its  rules,  restric- 
tions, and  evasions  of  responsibility,  while  the  railwa}r  managers  do  not 
deny  that  injuries  caused  by  derailment,  collisions,  etc.,  are  faults  for 
which  they  are  responsible,  yet  by  these  new  terms  inserted  in  the 
bill  of  lading,  the  burden  of  proof  is  on  the  owner  of  the  goods  ; 
and  from  the  nature  of  the  case,  unless  the  damage  shall  occur  in  an 
accident  of  such  magnitude  as  to  become  of  public  notoriety,  or  the 
property  is  delivered  in  such  a  condition  that  it  is  perfectly  apparent 
that  the  damage  must  have  occurred  while  in  their  hands  and  by  their 
acts,  the  owner  may  be  unable  to  procure  adequate  proof  to  est-iblish 
his  claim. 

It  is  therefore  claimed  that  we  ought  to  protest  against  these  new 
conditions  imposed  by  the  railway  companies,  and  the  practice  that 
has  been  in  vogue  from  time  immemorial  until  recent  date  be  re- 
sumed, that  the  carrier  shall  deliver  his  goods  in  like  apparent  good 
order  and  condition. 

If,  in  making  this  classification,  the  pre-existing  rates  or  classes 
have  been  lowered  a  class,  so  that  the  shipper  has  the  option  of  a 
lower  rate  than  before  by  accepting  a  new  contract  that  transfers  a 
part  of  the  responsibility  for  which  he  is  paid  in  the  lower  rate,  and 
the  shipper  chooses  the  new  rate  and  consequent  contract,  this  is 
entirely  legitimate ;  against  which  there  lies  yet  this  objection,  that 
while  the  proposed  option  might  by  strictly  equitable,  in  practice  it 
would  be  nearly  an  impossibility  to  carry  out  such  rules  and  provis- 
ions without  subjecting .  the  shipper  and  the  railway  company  to  an 
amount  of  labor,  in  constantly  making  these  contracts,  that  their 


6 


literal  enforcement  is  not  attempted  by  many,  if  any,  of  the  common 
carriers  of  the  country. 

When  the  matter  was  proposed  in  1878,  it  aroused  such  indignation 
that  public  meetings  were  at  once  held  in  this  city  by  the  Boston 
Board  of  Trade,  and  in  New  York,  and  it  was  soon  made  manifest  to 
the  railway  companies  that  they  had  gone  too  far,  and  the  proposed 
change  was  dropped  temporarily  ;  but  soon  some  of  the  railway  com- 
panies commenced  to  insert  O.  R.'s  in  their  local  receipts,  and  in 
1881,  we  find  one  of  the  largest  railways  in  New  England  had 
seventy  different  articles  in  their  tariff,  against  which  the}'  inserted 
"  O.  R."  ;  in  1885,  a  much  larger  number ;  but  no  tariff'  of  any  rail- 
way, either  East,  West,  North,  or  South,  have  we  found  that  ap- 
proached the  tariff  of  the  Joint  Committee,  wherein  they  put  O.  R. 
in  some  form  against  some  900  different  items  of  some  3,300  items 
which  are  inserted  in  their  book  of  classification  ;  and  we  venture 
the  opinion  that  the  cutting  up  the  classification  into  so  many  items 
is  unnecessarily  burdensome  to  both  the  railways  and  the  public. 
Should  it  be  said  that  the  railways  have  the  option  to  make  just  as 
many  items  of  billing  as  they  choose,  we  reply,  yes,  if  not  too  great 
an  inconvenience  to  the  public  ;  and  the  following  are  the  facts  as  to 
other  associations  which  have  considered  this  matter  :  — 

The  Transcontinental  Association  in  their  classification  put  some 
1,800  items,  of  which  120  are  O.  R.,  47  P.  P.  The  Southern  Rail- 
way and  Steamship  Association  some  1,300  items,  of  which  400  are 
O.  R.,  and  46  P.  P.  But  this  last  association,  in  each  of  the  "  O.  R." 
items  gives  the  option  of  carriers'  risk  at  a  higher  rate. 

The  Classification  Committee  of  the  New  England  railways,  at 
their  meeting  in  March,  1887,  appointed  at  a  previous  meeting  of 
thirty-three  of  the  presidents  of  New  England  railwa}Ts,  after  full 
discussion  and  consideration  for  three  da}Ts  decided  to  entirely  elim- 
inate O.  R.  from  their  classification,  with  the  following  exceptions  : 
Fruit,  fresh  meat,  vegetables,  and  furniture ;  and  they  there  limited 
the  O.  R.  in  relation  to  all  but  furniture,  to  what  might  result  from 
causes  from  which  the  common  law  releases  them,  viz.,  the  acts  of 
God,  in  heat  and  cold  and  effects  of  the  weather. 

As  to  furniture:  first  a  rate  is  given  without  the  O.  R.,  then  a 
lower  classification  and  rate,  if  the  shipper  chooses  to  accept  the  alter- 
native, and  only  some  one  thousand  four  hundred  items,  as  against 
some  three  thousand  three  hundred  of  the  Joint  Committee.  We  fully 
and  heartily  commend  the  action  of  the  New  England  Classification 


7 


Committee,  and  urge  its  adoption  by  all  the  common  carriers  of  the 
country,  so  that  we  may  not  be  brought  to  the  necessity  to  ask  of 
Congress  the  enactment  of  a  law  substantially  what  was  asked  by  the 
people  of  England,  and  put  into  force  by  the  enactment  by  Parliament 
of  the  following  law  in  1854  :  — 

"  That  every  railway  and  canal  company  shall  be  liable  for  the  loss 
of  or  any  injury  done  to  any  horses,  cattle,  or  other  animals,  or  to  any 
articles,  goods,  or  things  in  the  receiving,  .forwarding,  or  delivery 
thereof,  occasioned  by  the  neglect  or  default  of  such  company,  or  its 
servants,  notwithstanding  any  notice/ condition,  or  declaration  made 
or  given  by  such  company  contrary  thereto,  or  in  any  way  limiting 
such  liability,  every  such  notice,  condition,  or  declaration  being  hereby 
declared  to  be  null  and  void. 

"  Provided  alwa}^s  that  nothing  herein'contained  shall  be  construed 
to  prevent  the  said  companies  from  making  such  conditions  with  re- 
spect to  the  receiving,  forwarding,  and  delivering  such  animals  and 
goods  as  shall  be  adjudged  b}'  court  or  judge  before  whom  any  ques- 
tion relating  thereto  shall  be  heard,  to  be  just  and  reasonable." 

In  conclusion,  we  make  the  following  suggestions  :  — 

First.  We  think  the  principle  of  the  first  proposition  is  so  well  set- 
tled by  the  courts  of  this  country  and  England  that  no  action  is  rec- 
ommended by  your  committee. 

Second.  On  the  other  propositions  we  offer  the  following  resolu- 
tions, viz.  :  — 

Resolved,  That  in  the  opinion  of  this  association  it  is  the  duty  of 
common  carriers  to  issue  bills  of  lading  for  the  goods  received  for 
transportation,  and  to  deliver  thet goods  and  quantity  receipted  for,  or 
pay  for  the  deficiency  without  subjecting  the  receiver  to  expense  of 
litigation. 

Resolved,  That  we  believe  and  insist  that  all  merchandise  should  be 
delivered  to  the  receiver  on  payment  of  the  freight  specified  in  the  bill 
of  lading. 

Resolved,  That  we  heartily  approve  of  the  action  of  the  Classifica- 
tion Committee  of  the  New  England  railways  in  eliminating  from  their 
classification  and  tariff,  "  owner's  risk,"  and  we  strenuously  urge  the 
adoption  of  the  same  by  all  common  carriers. 

ALDEN  SPEARK. 
WILLIAM  O.  BLANEY. 
JEROME  JONES. 
JONA.  A.  LANE. 


Si>.  Q.  Si>.  <JV 


lilol  Ur 

Ju  Six  Lx.  Hi  uc  ±\  1  Jjxo. 

December  17,  1888. 

Littat  L1  TLiwi.1 

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Frank  A.  Davidson. 

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WILLIAM    IS.  I\ICE. 

Ciiari.es  A.  Dean. 

El)^'IN  l^OBINSON. 

Freeman  J.  Doe. 

Oscar  II.  Sampson. 

Samuel  Farquhar. 

William  H.  Sayward. 

Eustace  C.  Fitz. 

L.  P.  S.oule. 

James  B.  Forsyth. 

Alden  Spear. 

Hersey  B.  Goodwin. 

HOW  AIM)  W.  Spurr. 

Levi  S.  Gould. 

Cyrus  Thaciier. 

D.  S.  GiiiiENOUGH. 

Charles  I.  Thayer. 

James  M.  W.  Hall. 

Adams  K.  Tolman. 

George  s.  Harrington. 

Daniel  G.  Tyler. 

S.  J.  Harrison. 

M.  Everett  Ware. 

George  W.  Herrick. 

B.  B.  Whittemorb. 

J.  Edward  Hollis. 

George  M.  Win  slow. 

BOSTON 


Ex^eutiu^  Busir^ss  /tesoeiatiop. 


LIST  OF  ASSOCIATIONS  REPRESENTED. 

 ^_  

BAY  STATE  LUMBER  TRADE  ASSOCIATION; 

BOSTON  BOARD  OF  FIRE  UNDERW R  ITERS. 

BOSTON  CHAMBER  OF  COMMERCE. 
BOSTON  COAL  TRADE  ASSOCIATION. 

BOSTON  DRUGGISTS  ASSOC  IATION. 

BOSTON  FISH  BUREAU.  §|j 
BOSTON  FRUIT  AND  PRODUCE  EXCHANGE/* 
BOSTON  GROCERS  ASSOCIATION. 

BOSTON  MERCHANTS  ASSOCIATION. 
EARTHEN-WARE  AND  GLASS  TRADE  ASSOCIATION. 
-   BOSTON  PAPER  TRADE  ASSOCIATION. 

DRYSALTERY  CLUB  OF  NEW  ENGLAND 
NEW  ENGLAND  SHOE  AND  LEATHER  ASSOCIATION. 
NEW  ENGLAND  FURNITURE  EXCHANGE. 

NEW  ENGLAND  METAL  ASSOCIATION. 
OIL  TRADE  ASSOCIATION  OF  BOSTON. 

PAINT  AND  OIL  CLUB  OF  NEW  ENGLAND. 

THE   MASTER-BUILDERS  ASSOCIATION. 


